Regulations and Standards for
Fall Protection and Pedestrian Safety
Daniel R. Denton, Esquire
Copyright ©2014
Appendix to The Law of Slip & Fall, Daniel R. Denton, 2014
Below are summaries of some of the most relevant sections from various governmental
regulations and industry standards relating to safe walking surfaces and fall
protection, including those from International Codes Council (IBC, IPMC), Federal
Regulations (ADA & OSHA), private organizations (ANSI, ASTM, NFSI, UL) and South
Carolina codes.
INTERNATIONAL
International Code Council (ICC)1
The ICC was formed in 1994 by merging three regional model code associations which
separately published the National Building Code that governed the East and parts of
the Midwest; the Standard Building Code that governed the Southeast; and the
Uniform Building Code that governed the West and parts of the Midwest. Drawing upon
the three regional codes, the ICC worked to create model codes that would have
nationwide application, resulting in 15 International Model Codes, or I-Codes,
published by ICC. In addition to building, these codes included codes for electrical,
plumbing, mechanical, fire, etc. The I-Codes provide minimum standards for the
design, construction, and inspection of safe, sustainable structures for housing,
schools, and workplaces. All fifty states and the District of Columbia have adopted the
I-Codes at the state or local level, as have a number of federal agencies and more than
a dozen countries. Among the 15 I-Codes is the International Building Code (IBC), first
published in 1997. The IBC applies to all structures, except for one and two family
dwellings, which is covered by the International Residential Code (IRC).
Pursuant to S.C. Code § 6-9-50, every city and county in South Carolina that does not
“opt out” of the Code Enforcement Program must enforce the latest edition of the
reference mandatory building codes, which are the various codes issued by the IBC.
(See “South Carolina” at end of this Appendix.)
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IBC § 101.2 Scope. The provisions apply to the construction, alteration, repair,
equipment, use and occupancy of every building or structure or attachments.
IBC § 101.3 Intent. “The purpose of this code is to establish the minimum
requirements to safeguard the public health, safety and general welfare through
2002-2012 versions of the IBC and other I-Codes are available online at:
http://publicecodes.cyberregs.com/icod/ibc/.
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structural strength, means of egress facilities . . . and safety to life and property
from fire and other hazards attributed to the built environment . . . .”
IBC § 1003.4 Floor surface. Walking surfaces of the means of egress shall
have a slip-resistant surface and be securely attached.
IBC § 1003.5 Elevation change. Where changes in elevation of less than 12
inches exist in the means of egress, sloped surfaces shall be used. Where the
slope is greater than 5%, ramps shall be used. Where the difference in elevation
is 6 inches or less, the ramp shall be equipped with either handrails or floor
finish materials that contrast with adjacent floor finish materials. Certain
exceptions apply involving use of a single step.
IBC § 1003.6 Means of egress continuity. The path along a means of
egress shall not be interrupted by any building element, except as specified and
no obstructions are allowed.
IBC § 1008.1.3.1 Revolving doors. Specifies location and RPM speed
limitations for power-assisted and manual revolving doors.
IBC § 1008.1.3.2 Power-operated doors. Has power failure and opening and
closing force requirements. Full-power-operated doors shall comply with BHMA
A156.10. Power-assisted and low-energy doors shall comply with BHMA
A156.19. (See Section, Private/ANSI).
IBC § 1009 Stairways. For interior and exterior stairways, specifies width,
dimensions and construction details of treads, risers, landings and headroom.
IBC § 1009.9.1 Stairway walking surface. Treads and landings shall not be
sloped more than 2% and shall have a solid surface, with finish floor surfaces
securely attached.
IBC § 1009.15 Handrails. Stairways shall have handrails on each side.
Dwelling units only require one handrail and none are required for three or
fewer steps. Other exceptions apply.
IBC § 2103.6 Ceramic Tile. The IBC does not specify coefficient of friction
(COF) values or refer to any slip resistance standard. However, ceramic tiles
shall conform to the requirements of ANSI A137.1, which specifies a minimum
dynamic COF of 0.42 “for level interior spaces expected to be walked upon when
wet.”
The International Property Maintenance Code (IPMC)
Published by the ICC, “[t]he IPMC is a model code that regulates the minimum
maintenance requirements for existing buildings. It is a maintenance document
intended to establish minimum maintenance standards for basic equipment . . .
sanitation and fire safety. Responsibility is fixed among owners, operators and
occupants for code compliance. The IPMC provides for the regulation and safe use of
existing structures in the interest of the social and economic welfare of the
community. This code is founded on principles intended to establish provisions
consistent with the scope of a property maintenance code that adequately protects
public health, safety and welfare.” As of this book's publication, the IPMC has not
been adopted as one of the mandatory codes under S.C. Code § 6-9-50. See last
section of this Appendix for South Carolina codes.
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§ 101.2 Scope. Applies to all existing residential and nonresidential structures
and constitute minimum requirements and standards for premises, structures,
equipment and facilities for building elements and for life safety, safety from fire
and other hazards, and for safe and sanitary maintenance; the responsibility
of owners, operators and occupants; the occupancy of existing structures
and premises, and for administration, enforcement and penalties.
§ 102.3 Application of other codes. Repairs, additions or alterations to a
structure, or changes of occupancy, shall be done in accordance with the
procedures and provisions of the International Building Code.
§ 102.5 Workmanship. Repairs, maintenance work, alterations or installations
shall be executed and installed in a workmanlike manner and installed in
accordance with the manufacturer’s instructions.
§ 108.1.1Unsafe structures. Those found to be dangerous to the life, health,
property or safety of the public or the occupants of the structure.
§ [A] 108.1.2 Unsafe equipment. Includes any boiler, heating equipment,
elevator, moving stairway, or other equipment on the premises or within the
structure which is in such disrepair or condition that such equipment is a
hazard to life, health, property or safety of the public or occupants of
the premises or structure.
§ 108.1.5 Dangerous structure or premises. Any structure or premises that
have any of these conditions or defects shall be considered dangerous:
1. Any door, aisle, passageway, stairway, exit or other means of egress
that does not conform to the approved building or fire code.
2. The walking surface of any aisle, passageway, stairway, exit or other
means of egress is so warped, worn loose, torn or otherwise unsafe as to
not provide safe and adequate means of egress.
§ 302.3 Sidewalks and driveways. Sidewalks, walkways, stairs, driveways, parking
spaces and similar areas "shall be kept in a proper state of repair, and maintained free
from hazardous conditions.”
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§ 304.10 Stairways, decks, porches and balconies. Every exterior stairway,
deck, porch and balcony, and all appurtenances attached thereto, shall be
maintained structurally sound, in good repair
§ 304.12 Handrails and guards. Every handrail and guard shall be firmly
fastened and capable of supporting normally imposed loads and shall be
maintained in good condition.
§ 304.15 Doors. All exterior doors, door assemblies, operator systems if
provided, and hardware shall be maintained in good condition.
FEDERAL
Americans with Disabilities Act (ADA)2
The 2010 ADA Standards for Accessible Design are available online in html and pdf at
http://www.ada.gov/2010ADAstandards_index.htm.
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The ADA requires certain public and private facilities to be accessible to persons with
disabilities. In 2010 the Justice Department adopted new Standards for Accessible
Design (ADASAD). The ADA does not cover residential facilities, which is under the
jurisdiction of the Federal Fair Housing Act. The companion Advisory Guidelines
(ADAAG) generally apply to new construction and to certain alterations of structures
and are for both State and local government facilities (Title II) and public
accommodations and commercial facilities. The stated purpose of the handicapped
access standard is to make buildings and facilities accessible and usable by people
with physical disabilities. While the standard is drafted to be adopted as a model code
by governmental agencies, it is also intended to be used by nongovernmental parties
as technical design guidelines. The ADA requirements “were promulgated for the
benefit of physical impaired individuals, making their relevance to the ambulation of
the able-bodied arguable.”3
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28 CFR § 36.403(e). A "path of travel" includes a continuous, unobstructed
way of pedestrian passage. An accessible path of travel consists of walks and
sidewalks, curb ramps and other interior or exterior pedestrian floor paths and
ramps.
§ 302.1 Floor or Ground Surfaces. Shall be stable, firm and slip-resistant.
o Advisory 302.1 General. A stable surface is one that remains unchanged
by contaminants or applied force, so that when the contaminant or force is
removed, the surface returns to its original condition. A firm surface resists
deformation by either indentations or particles moving on its surface. A slipresistant surface provides sufficient frictional counterforce to the forces
exerted in walking to permit safe ambulation.
o ADAAG recommends that walking surfaces have certain COF slip resistance,
but no standards or methods of measurement are specified in scoping or
technical provisions.
§ 303 Changes in Level. Changes in level between 1/4 and 1/2 inch shall be
beveled with a slope no greater than 1:2. Changes in level greater than 1/2 inch
shall be accomplished by means of a ramp that complies with certain
standards.
§ 302.2 Carpet. Carpet used on a floor or ground surface shall be securely
attached; have a firm cushion, pad, or backing, or no cushion or pad; and have
a specified loop, pile and thickness. Exposed edges of carpet shall be fastened
to floor surfaces and have specified trim.
§ 504 Stairways. Specifies dimensions for uniform riser heights and tread
depths. Stair treads and landings subject to wet conditions shall be designed to
prevent the accumulation of water.
§ 505 Handrails. Generally, handrails are required on both sides of stairs and
ramps. Top of gripping surfaces shall be 34-38 inches.
Steven Pi Dilla, Slip, Trip, and Fall Prevention: A Practical Handbook, 165 (2nd Ed. 2010). This book is
intended for use by safety professionals and concentrates on the principles and measurement of slip
resistance, but includes extensive coverage of fall protection standards, best practices for facility design,
hazard recognition and prevention guidelines, checklists, case studies, online resources, and an extensive
bibliography. The 2003 first edition of this book is available for free download at several websites,
including www.bookbay.org and www.docstoc.com.
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§ 609 Grab Bars. Size, spacing, location and structural strength requirements
specified for toilet and bathing facilities; and shall be free of sharp or abrasive
elements and shall have rounded edges.
Occupational Safety and Health Administration (OSHA)4
OSHA implemented fall protection and walking surface standards for general,
construction and other industries requiring employers to ensure fall restrictive or
limiting devices are used to prevent inadvertent falls. Twenty-five states, including
South Carolina, have OSHA-approved state plans, which for the most part adopt
standards that are identical to Federal OSHA. While the standards apply to employers,
arguably the inspection requirements should reasonably include hazards that may be
presented to the general public by the conditions at the job site where non-employees
may encounter the conditions on the premises.
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Typical OSHA Fall Protection Areas Include:
o Walkways, stairways, ladders and floor openings
o Scaffolding and elevated work platforms
o Rooftops and all leading edge locations
o All baskets and powered man-lifts
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Fall Protection Regulations
o 29 CFR 1910 Subpart D – Walking and Working Surfaces (General Industry)
o 29 CFR 1926 Subpart M – Fall Protection (Construction Industry)
o 29 CFR 1926 Subpart L – Scaffolding
o 29 CFR 1926 Subpart X – Ladders
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Summary of Relevant Fall Protection Standards
o Floors must be kept dry and free of obstructions (1910.22(a)(2).
o Slip resistance for walking surfaces – No mandate, but recommends a COF
of 0.5; no specification of a test method, standard, or test instrument
(1910.22).
o Mats or other dry standing places should be provided where practicable
(1910.22).
o Aisles and passageways shall be kept clear and in good repairs, with no
obstruction across or in aisles that could create a hazard (1910.22(b)(1)).
o Provide warning signs for wet floor areas. Accident Prevention Signs and
Tags Standard (1910.145(c)(2)).
o Every flight of stairs having four or more risers shall be equipped with
standard stair railings or standard handrails (1910.23).
o Employees exposed to fall risks must be trained and equipped in the
prevention of injuries associated with slip, trip and fall hazards (1926.21 &
1926.503).
o Stairway openings, ramps, walkways and other work areas exposed to
greater than 6 feet height must be guarded (1926.501).
The OSHA law and regulations are available online at https://www.osha.gov/law-regs.html.
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Open sided floors or platforms 4 feet or more above adjacent surfaces must
be appropriately guarded (1910.23).
Ladders and scaffolding must be designed, constructed and used per
applicable standards.
Ladders shall extend at least 3 feet above the working surface
(1926.1053(b)(1)).
A proposed rule change for 29 CFR, 1910, Subpart D, would require a
“qualified person” – one with special training – to inspect, maintain, and
repair walking and working surfaces.
PRIVATE
The following private organizations publish voluntary standards and have no role in
requiring or enforcing compliance with its standards. Any of the standards, however,
may become mandatory, and/or constitute standards of care owed to others, when
incorporated by contract, or when adopted by a company or other entity, or adopted
by a governmental agency or political subdivision.
American National Standards Institute (ANSI)
A nonprofit organization that oversees the development of standards and guidelines
across a wide array of business sectors to enhance global competitiveness of American
businesses while assuring the safety and health of consumers and the protection of
the environment.5
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ANSI/ASSE A1264.2-2012. Provision of Slip Resistance on Walking/Working
Surfaces.
o Applies only to workplaces rather than the general public.
o Has provisions for “protecting persons where there is potential for slips
and falls as a result of surface characteristics or conditions.”
o Addresses floor surface characteristics, footwear traction properties,
environmental factors, and human factors.
o Selection of walkway surface material.
o Pre-accident (and post) warnings, including signage and placement.
o Recommends that mats or runners be used in some locations to reduce slipping
hazards.
o Addresses housekeeping training and maintenance, surface testing and floor
selection.
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Recommends that floors meet a minimum dry SCOF of 0.5.
ANSI/ASSE A1264.1-2007. Safety Requirements for Workplace Walking &
Working Surfaces and Their Access; Workplace, Floor, Wall and Roof Openings;
Stairs and Guardrails Systems.
The copyrighted ANSI standards may be purchased online at http://webstore.ansi.org/.
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Provides safety requirements for workplace areas where danger exists of
persons from objects falling through floor or wall openings, platforms,
runways, ramps and fixed stairs.
Includes requirements for slip resistance
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ANSI/ASSE TR-A1264.3-2007. ANSI Technical Report: Using Variable Angle
Tribometers (VAT) for Measurement of the Slip Resistance of Walkway Surfaces.
o Provides guidance for slip resistance testing.
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ANSI/NFSI B101.1-2009. Test Method for Measuring Wet SCOF of Common
Hard-Surface Floor Materials.
o First uniform test for all walkway surfaces.
o Specifies the procedures and devices used for testing to measure the wet
static COF of common hard-surface floor materials.
o Rather than categorizing walkways as safe or unsafe based upon a
single COF value, the standard identifies three wet SCOF risk categories,
or “traction ranges”: high traction (0.6 and higher), moderate traction
(0.4 to 0.6), and low traction (less than 0.4).
o Recommends remediation plans for each level.
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ANSI/ASSE A10.18-2007. Temporary Roof & Floor Holes, Wall Openings,
Stairways Safety Requirements for, & Other Unprotected Edges in Construction &
Demolition Operations.
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ANSI/BHMA A156.10: Standard for Power Operated Pedestrian Doors.
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ANSI/BHMA A156.19: Standard for Power Assist and Low Energy Power
Operated Doors
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ANSI/MHNA A156.27-2011 Standard for Power and Manual Operated
Revolving Pedestrian Doors
ASTM International
An international standards organization (formerly known as the American Society of
Testing Materials) that develops voluntary consensus technical standards for a variety
of products, materials and services. ASTM members, more than 30,000 of the world’s
top technical experts and business professionals representing 150 countries, provide
the test methods, specifications and standards that support industries and
governments worldwide. ASTM is the most active in the development of pedestrian
safety related standards in the U.S.6
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ASTM F1637-13. Standard Practice for Safe Walking Surfaces.
o § Scope – Covers design and construction guidelines and minimum
maintenance criteria for new and existing buildings and structures.
Purchase copyrighted standards online at http://www.astm.org/Standard/.
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§ 5.1 & 5.2. Walkways – Shall be stable, planar, flush, even and slip
resistant under expected environmental conditions and use; if interior
walkways are not slip resistant when wet, then they shall be maintained
dry during periods of pedestrian use. Changes in levels greater than 1⁄2
in. shall be transitioned by means of a ramp or stairway.
§ 5.3. Carpet – Shall be maintained so as not to create pedestrian
hazard by being firmly secured and not having loose or frayed edges,
wrinkles or other trip hazards that may cause trip.
§ 5.4. Mats – To be placed at building entrances and interior walkways
where needed to keep them dry during inclement weather and shall be
maintained so as not to create pedestrian hazards, as shall area rugs.
§ 5.5. Illumination – Minimum walkway illumination governed by the
requirements of local codes; shall be designed to be glare free to avoid
casting of obscuring shadows on walkways and stairs; pedestrian use
areas, including parking lots, shall be properly illuminated.
§ 5.7. Exterior walkways – Shall be maintained so as to provide safe
walking conditions and shall be slip resistant; and repaired or replaced
where there is an abrupt variation in elevation between surfaces.
§ 7.1. Stairways – Distracting views shall be avoided that can attract the
stair user’s attention, i.e., advertisements and store displays; step
nosings shall be readily discernible and slip resistant; short flight stairs
shall be avoided where possible, but if used, obvious visual cues shall be
provided, such as handrails, delineated nosing edges, contrast in surface
colors, etc.
§ 8. Speed Bumps – To be avoided when designing; if in foreseeable
pedestrian paths they shall comply with § 5.2 (walkway changes in level)
and if not, they shall have safety color coding to contrast with
surroundings.
§ 9. Wheel Stops – Parking lots should be designed to avoid their use;
they shall not be placed in pedestrian walkways or foreseeable pedestrian
paths; and shall be in contrast with their surroundings.
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ASTM F1694-09. Standard Guide for Composing Walkway Surface Evaluation &
Incident Report Forms for Slips, Stumbles, Trips & Falls.
o “This guide provides recommendations for recording walkway surface
investigation, evaluation, and incident report data pertaining to slips,
trips, stumbles, and falls.”
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ASTM F2965 – 13. Standard Guide for Selection of Walkway Surfaces and
Treatments When Considering Aggressive Contaminant Conditions in Commercial
and Industrial (Not Including Construction) Environments.
o § 1.1. Intended to assist in the selection of walking surfaces and
treatments where the foreseeable presence of aggressive contaminants
produces the danger of slip and falls in commercial and industrial (not
including construction) environments, for persons wearing appropriate
footwear.
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§ 5.1 The slip hazard from aggressive contaminants on walkway surfaces
is often found in commercial and industrial (not including construction)
settings including fresh fruits and vegetables open display areas,
manufacturing processes, food preparation and processing areas….
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§ 5.2 Ladder rungs, steps and other similar means of access and egress
should be considered as walkway surfaces in slip-resistance analyses in
commercial and industrial (not including construction) environments
where aggressive contaminants are determined to be a factor.
National Floor Safety Institute (NFSI)
A nonprofit organization focused on slip, trip, and fall prevention through education,
research, and standards development. NFSI provides organizations with an
opportunity to have their floors assessed and certified. In 2006, NFSI was accredited
to be an ANSI standards developer.
The NSFI also provides product testing and certifies flooring materials, coatings,
cleaning materials, and treatments according to these standards:
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NFSI 101-A. Standard for Measuring Wet SCOF of Common Walkway Materials
and Coatings.
NFSI 101-B. Standard for Measuring Wet SCOF of Chemical Floor-Cleaning
Agents and Treatments.
NFSI 101-C. Test Method for Measuring Dry TCOF of Floor Mat Backing
Materials.
Underwriters Laboratories (UL)
A nonprofit product safety testing and certification organization.
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UL-410. Slip Resistance of Floor Surface Materials
o “These requirements cover the testing of floor and finishing materials to
determine if their minimum average and minimum individual static
coefficients of friction meet or exceed the specified requirements with
respect to slip resistance only.”
o Similar to ASTM D-2047.
SOUTH CAROLINA
S.C. Code § 6-9-5. Public policy for building codes
“(A) The public policy of South Carolina is to maintain reasonable standards of
construction in buildings and other structures in the State consistent with the public
health, safety, and welfare of its citizens. To secure these purposes, a person
performing building codes enforcement must be certified by the South Carolina
Building Codes Council, and this act is necessary to provide for certification.”
Building Codes in Effect for South Carolina7
Every city and county in South Carolina that does not “opt out” of the Code
Enforcement Program must enforce the latest edition of the mandatory building codes
referenced in S.C. Code § 6-9-50 after they have been reviewed and adopted by the
Building Code Council. Mandatory building codes adopted for current use in South
Carolina which must be enforced by local jurisdictions include:
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2003
2003
2003
2003
2003
2003
2003
2002
International Building Code (IBC) with S.C. modifications.
International Residential Code (IRC) with S.C. modifications.
International Fire Code with S.C. modifications.
International Plumbing Code.
International Mechanical Code.
International Energy Conservation Code.
International Fuel Gas Code with S.C. modifications.
National Electrical Code.
Jurisdictions that have legally opted out of the code enforcement program at this time
include the Towns of Richburg, Ehrhardt, and Pamplico, and the County of Union.
Permissive Codes
As allowed by S.C. § 6-9-60, other “nationally recognized codes” may be adopted as
needed by a local jurisdiction, but the codes must be adopted by ordinance before
enforcement can begin. The permissive codes include:
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2003 International Property Maintenance Code.
2003 International Existing Building Code.
2003 International Performance Code for Buildings and Facilities.
Accessibility Act and Other Accessibility Laws
The Accessibility Act required adoption of the 1998 ICC/ANSI A117.1, Accessible and
Useable Buildings and Facilities, and is mandatory for use in all jurisdictions within
the state. Additional accessibility laws that apply in South Carolina include:
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Americans with Disabilities Act (ADA).
Fair Housing Act Amendments of 1988.
South Carolina Fair Housing Law.
The IBC Codes adopted in South Carolina are available online for free viewing at
http://publicecodes.cyberregs.com/st/sc/. For implementation history and other information, see South
Carolina Building Codes Council at http://www.llr.state.sc.us/pol/bcc/.
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Daniel R. Denton, Esquire
Copyright ©2014